EPA has not defined the frequency or scope of sampling and testing that is necessary to meet the quality assurance program defense element, because there is no single program that is appropriate in all situations. In addition, EPA believes that regulated parties are most familiar with their own operations, and therefore are in the best position to design quality assurance programs that are adequate to ensure the RFG standards are met.

Factors that EPA believes are relevant in designing an RFG quality assurance program are: the results of previous sampling; the volume of gasoline in a particular batch (the larger the volume, the greater the justification for sampling and testing that batch); the degree of confidence in the quality of the gasoline which was received; the opportunity for violations while the gasoline is in the possession of the party (e.g., the opportunity for commingling of RFG and conventional gasoline); and the opportunity to deliver RFG in a manner inconsistent with the proper time and place of use.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)